That this case has emerged internally gives us an opportunity to ensure that situations like this do not arise out of our control, i.e. discovered by a customer. We have the opportunity to built our compliance and audit procedures from scratch, so that the level of oversight these departments have on the firm's operations is complete, and insulates the firm against further risk. An investigation should be conducted into past auditing and compliance practices so we can know precisely where the failures occurred and this information will help us to correct those practices in the future.

The third recommendation is that the Board gives consideration to upgrading the bookkeeping system. It is clear that manual updates are unreliable and that reliance on them puts the company at risk. We know this now, on the basis of the preliminary investigation, so this is something that we can deal with now. The...
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